CMIOs share early thoughts on Stage 2 meaningful use

Buzz from last week's announcement of the notices of proposed rulemaking (NPRM) for Stage 2 of meaningful use pertaining to the Medicare and Medicaid EHR Incentive Programs has settled into efforts to understand just how the new requirements affect providers. In recent exclusive interviews, CMIOs of Rockingham Memorial Hospital (RMH) in Harrisonburg, Va., and St. Francis Hospital in Wilmington, Del., offered early opinions on the NPRM.

The proposed rule offered few surprises but one point of shared enthusiasm among the CMIOs is that the quality measures in the Stage 2 proposed rule begin to align with other quality-reporting initiatives from agencies like the Centers for Medicaid & Medicaid Services. “It was good to see that stressed,” said Brian P. McDonough, MD, CMIO of St. Francis. “What I really wanted to see in Stage 2 was the requirement of consistent communication and we are seeing the beginnings of that in Stage 2.”

Robert M. Underwood, MD, CMIO of RMH, echoed this, “We knew that the focus of Stage 1 was more on collecting data and that Stage 2 would be more focused on sharing data. That’s coming to fruition; which is appropriate. One of my concerns with Stage 1 was collecting data and reporting that same data through different quality measures/agencies.”

As noted by previous pundits, one change to Stage 2 requirements is that 10 percent of patients must access their online clinical information electronically. As McDonough mentioned, the regulations are moving more toward the direction of a patient portal to get patients more involved in their care. Patient education will be necessary to meet this measure, said Underwood, but he does not think it will be difficult for the RMH patient population to hit this measure. However, he noted the comment period could be marked by an outcry of providers saying, “We can’t make our patients access that.”

However, according to Underwood, if a practice provides the capability of access and makes it functional for the patient, those that want to use the tool will likely use them and be invested in their care.

One surprise that Underwood noted involved the proposed measure of more than 50 percent of all patients discharged from the inpatient or emergency department of an eligible hospital or critical access hospital having their information available online within 36 hours of discharge. This is a question of how data are derived and gathered, Underwood stated, adding that a fully formed EMR could be processing clinical information in real-time or if data are abstracted post-discharge, this could only give room to upload the data in one working day. “We’ll have to dig more into the regulation and the specifics on that one to prepare for it.”

The NPRM weighs in at 455 pages so it will take time for CMIOs to fully decipher some of the heady language and its implications to an organization. For example, the proposed rule requires the successful ongoing submission of electronic syndromic surveillance data from certified EHR technology to a public health agency for the entire EHR reporting period. This is a jump from just being a test before in Stage 1 as a menu item. Underwood is unsure if “ongoing submission of electronic syndromic surveillance data” means 100 percent are reported. “I’ll be more interested once we get into the weeds of it,” he said.

The disparity between the ground level of clinical care and the federal lawmaking offices is crucial going forward with meaningful use measures. The comment period will be important, according to McDonough. “Physicians are going to have to have more of a voice getting their point-of-views across in the comment period,” he said. “The government officials, for obvious reasons, don’t know what clinicians know but they want to learn and are going to write regulations based on their interpretations of what they hear. CMIOs are the ones who know and are aware of the clinical side. They should be representatives for the clinicians and physicians to government officials. Because meaningful use stages can do different things, by the time we get to Stage 3, we should have our voices heard.”

RMH is currently working hard on Stage 2 requirements while getting ready to attest for Stage 1. According to Underwood, RMH is attesting on an ambulatory platform in a couple of months and attesting on the inpatient side in spring 2013. He said that knowing meaningful use Stage 2 requirements is helpful while working toward Stage 1. “It’s manageable because we’re so familiar with Stage 1,” he said. For example, while RMH is building out a computerized physician order entry system, they plan on meeting Stage 2 requirements when they turn the system on. “Yes, let’s meet Stage 1 but let’s not lose sight of Stages 2 and 3 where the requirements are going to be set to higher thresholds.”

McDonough suggested that the government, in the proposed regulations, understood that organizations would be varied in terms of their Stage 1 onboarding, resulting in the requirement that those attesting to meaningful use first in 2011 or 2012 must meet Stage 2 in 2013 and Stage 3 in 2016. Others will be required to demonstrate two years at Stage 1, two years at Stage 2 and then two years at Stage 3. “Three primary factors relate to this: Organizations using different EHR platforms, having different support structure and amounts of time and experience leading into their efforts,” said McDonough.

Underwood concluded with two pieces of advice for those in the early stages of attestation while looking toward later stages:

• Involve the physicians early on and have them understand the impact on workflow the requirements may have; and
• Communicate with your team often.